1.1. This privacy policy (“Policy”) relates to the websites/apps/applications (including Insight) and any subdomain or any such related websites/apps/applications and/or mobile applications for such websites/apps/applications (together with the “Website/app” or “application”).
1.2. You should read this Policy carefully as it contains important information about how we will use your Information (as defined below in clause 4.1). In certain circumstances (see below) you will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit such Information to or through the websites/apps/applications. For further information about consent see clause 7 below.
1.3. We may update this Policy from time to time in accordance with clause 17 below. This Policy was last updated on 20th November 2024.
1.4 If you have been referred to Innovate by your Local Authority (Council) and we are providing you with support through the websites/apps/applications, the information you provide will be shared with your Local Authority as part of your care plan/support package and in managing the contract.
2.1. The terms “Insight” or “us” or “we” refer to Innovate Trust Ltd, the owner of the websites/apps/applications. We are a company registered in England and Wales under company number 02493904 whose registered office is at Innovate Trust, 433 Cowbridge Road East, Canton, Cardiff, CF5 1JH. The term “you” refers to the individual accessing and/or submitting Information to the websites/apps/applications.
2.2. We, as the Data Controller, can be contacted via our representative via email info@innovate-trust.org.uk or phone on 02920 382151.
3.1. References in this Policy to:
3.2. For the purposes of applicable Privacy and Data Protection Requirements, we (Innovate Trust) are a Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Privacy and Data Protection Requirements. “Personal Data” has a legal definition but, in brief, it refers to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Such information must be protected in accordance with applicable Privacy and Data Protection Requirements.
4.1. When you use the websites/apps/applications and/or when you otherwise deal with us we may collect the following information about you (“Information”):
4.2. We may monitor your use of the websites/apps/applications through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the websites/apps/applications. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. See clause 16 below for further information on our use of cookies.
4.3. Occasionally we may receive information about you from other sources, for example, our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, or search information providers you connect with through the websites/apps/applications, by your Local Authority (Council) as part of your care plan/support package or from any third-party websites/apps/applications that integrate or communicate with the websites/apps/applications in relation to you. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
5.1. Subject to clause 5.2, we will keep your Data only for the purposes set out in the table below for:
5.2. If required, we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
6.1. From 25 May 2018, under applicable Privacy and Data Protection Requirements, we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is set out in the list below.
Why we will process your Information | The legal basis for which is… |
to support accounts that you sign-up for | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to enable higher-level account holders to identify you (for example, staff in your own organisation/institution that uses or subscribe to our services may view data about you). | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to send you company and relevant updates by email, such as news and important changes. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to research into usage and behaviour for improving and changing our services, including personalisation to your needs. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to operate, administer, maintain, provide, analyse and improve the websites/apps/applications and the services available to you through the websites/apps/applications. | this is necessary for the performance of the contract between us and information is processed to enable us to provide services to our users. |
to investigate and address any comments, queries or complaints made by you regarding the websites/apps/applications or our services, and any similar or related comments, queries or complaints from other user. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to ensure that content from the websites/apps/applications is presented in the most effective manner for you and for your device. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to allow you to participate in interactive features of the websites/apps/applications, including inputting information and providing feedback. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
to notify you about changes to the websites/apps/applications. | this is necessary for the performance of the contract between us and Information is processed to enable us to provide services to our users. |
where required by (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity. | this is necessary to comply with our legal obligations, including obligations relating to the protection of Personal Data. |
to disclose your information to selected third parties as permitted by this Policy (see clause 9 below); | this processing is subject to your continued consent to the processing of your data for that specific purpose (see ‘Marketing and opting out’ in clause 8 below); |
7.1. As noted above, you will be required to give consent to certain processing activities before we can process your Information as set out in this Policy. Where applicable, we will seek this consent from you when you first submit Information to or through the websites/apps/applications.
7.2. If you have previously given consent you may freely withdraw such consent at any time. You can do this by notifying us in writing at info@innovate-trust.org.uk.
7.3. If you withdraw your consent, and if we do not have another legal basis for processing your information (see clause 6 above), then we will stop processing your Information. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights (for which see clause 14 below).
7.4. Please note that if we need to process your information to operate the websites/apps/applications and/or provide our services, and you object or do not consent to us processing your Information, the websites/apps/applications and/or those services may not be available to you.
7.5 If you have been referred by your Local Authority (Council) and we are providing you with support through the websites/apps/applications the information you provide will be shared with your Local Authority as part of your care plan/support package and in managing the contract. If you have been referred to us from your Local Authority Social Services, your consent is not needed to share your information.
8.1. You have the right at any time to ask us to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to info@innovate-trust.org.uk, or by using the tools available via the websites/apps/applications. Alternatively, you can follow the unsubscribe instructions in emails you receive from us and under your profile settings.
9.1. We may disclose your Information (including Personal Data):
9.2 We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the websites/apps/applications. In such circumstances, we do not disclose any information which can identify you personally.
10.1. We will use technical and organisational measures in accordance with good industry practice to safeguard your Information, including the use of passwords, multi-factor authentication (wherever possible), antivirus and antimalware software, and data encryption.
10.2. While we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
We may monitor and record communications with you (such as emails or conversations via the websites/apps/applications) for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed in clause 6 above.
12.1. From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (“EEA”). Non-EEA countries that we may need to transfer your Information to include:
12.2. Such countries may not have similar protections in place regarding the protection and use of your data as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with applicable Privacy and Data Protection Requirements to ensure adequate protections are in place to ensure the security of your Information.
12.3. By submitting your information to us in accordance with this Policy, you consent to these transfers for the purposes specified in this Policy.
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Information; receive on his/her/their behalf any data protection notices, and give consent to the transfer of his/her/their Information abroad (if applicable).
If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details in clause 20 below) giving us enough information to identify you and respond to your request.
14.1. You have the right to request access to information about Personal Data that we may hold and/or process about you, including whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
14.2. You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information to deal with the change or correction.
14.3. You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case, we will let you know.
14.4. You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see clause 14.6 below).
14.5. You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you, we will let you know.
14.6. You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
14.7. We do not use automated processing for the purpose of profiling or decision making, but if we did, you would have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we would let you know.
14.8. You have the right to object to direct marketing, for which see clause 8.3 above.
15.1. We welcome your feedback and questions on this Policy. If you wish to contact us, please email us at info@innovate-trust.org.uk or call on 02920 382151.
15.2. If you have any concerns about how we collect or process your Information then you also have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.
16.1. Our software may issue ‘cookies’ (small text files) to your device when you access and use the websites/apps/applications and you will be asked to consent to this at the time (e.g. when you first visit our websites/apps/applications). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
16.2. Our websites/apps/applications use cookies and other tracking and monitoring software to: distinguish our users from one another; collect standard Internet log information; and to collect visitor behaviour information. The information is used to track user interactions with the websites/apps/applications and allows us to provide you with a good experience when you access the websites/apps/applications, helps us to improve our websites/apps/applications, and allows us to compile statistical reports on the websites/apps/applications visitors and activity.
16.3. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however, please note that some of our websites/apps/applications features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.
17.1. We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on this page, and place notices on other pages of our websites/apps/applications as applicable, so that you may be aware of the Information we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version of this Policy as it will apply each time you access our websites/apps/applications.
18.1. Our websites/apps/applications may contain links to other websites/apps/applications. This Policy only applies to our websites/apps/applications. If you access links to other websites/apps/applications any Information you provide to them will be subject to the privacy policies of those other websites/apps/applications.
18.2. We have no control over third party websites/apps/applications or systems and accept no legal responsibility for any content, material or information contained in them. Your use of third party sites or systems will be governed by the terms and conditions of that third party. It is your responsibility to ensure you are happy with such third-party terms and conditions.
18.3. The display of any hyperlink and/or reference to any third-party websites/apps/applications, system, product or service does not mean that we endorse that third party’s websites/apps/applications, products or services and any reliance you place on such hyperlink, reference or advert is done at your own risk.
This Policy aims to provide you with all relevant details about how we process your information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
Our mobile application will request access to:
You have the right to decline and/or remove access to this via your settings at any time. We have this option available as we use webRTC to allow for video and audio communication via a third party, within our app for users.
21.1 Approval Process
All organisations and their representatives or employees must undergo an approval process before they can use our websites/apps/applications. This process includes verifying the organisation’s legitimacy and the authenticity of its representatives or employees. We reserve the right to request additional information or documentation as part of this process.
21.2 Responsibility for Access
Organisations are responsible for notifying us immediately if an employee who has access to our websites/apps/applications leaves the organisation or no longer requires access. Failure to do so may result in unauthorised access, for which the organisation will be held accountable if any issues arise.
We are not responsible for any issues arising from posts, events, or other actions within our websites/apps/applications by an organisation, its representatives, or its employees.
Access to our websites/apps/applications using an account representing an organisation or as an employee of an organisation should be used strictly for work purposes related to the organisation’s activities only. Any misuse, misrepresentation, or other activity for personal or non-work-related purposes is prohibited and may result in the termination of access.
As part of our onboarding process, we provide organisations or group organisers with the ability to post events to the events section of our websites/apps/applications. We take no responsibility for events posted or shared.
23.1 Events
Only representatives of organisations or employees, groups, volunteers or peer-led members that have been provided access or authorisation are granted permission to post events on our websites/apps/application.
While we do our best to ensure the authenticity of the posters during the onboarding process, we do not endorse or verify all the events listed.
We are not responsible for any issues arising from the events posted, including but not limited to cancellations, changes, charges or inaccuracies.
Users should verify event details directly with the event organisers identified at the bottom of the event. Events are not always attended by an employee of Innovate Trust.
Organisations, representatives, or employees posting events are accountable for events posted from their own accounts. We reserve the right to remove and/or delete events without any notice.
We disclaim all liabilities for any damages or losses incurred as a result of participating in or relying on the events posted on our websites/apps/applications. Users participate in events at their own risk.
Some events may be restricted to individuals over the age of 18. Organisations, representatives, or employees are responsible for correctly listing events and labelling the event with the correct age restrictions.
It is important for users to check the appropriateness of the event before participating and consider its content suitability.
23.4 Right to Remove
We reserve the right to remove any user or event from our websites/apps/applications at our sole discretion, without prior notice. This includes but is not limited to events that violate our terms, are deemed inappropriate, or are reported by other users.
23.5 Safeguarding
We are committed to the safeguarding of vulnerable people and adhere to safeguarding guidelines. However, users should exercise caution and ensure their own safety when participating in events posted by third parties. Users should raise any concerns directly with us by emailing info@innovate-trust.org.uk or contacting an official Innovate Trust employee.
24.1 Overview
The Volunteer Hub is a feature of our websites/apps/applications, designed to connect adults with disabilities to volunteer opportunities. These opportunities are submitted by representatives or employees of various organisations.
Our websites/apps/applications contain an integration with our Volunteering Hub. This policy also applies to the ‘Volunteering Hub’. By accessing the Volunteering Hub, you are agreeing to the same terms and conditions and privacy policy as outlined throughout our websites/apps/applications.
24.2 External Links and User-Generated Content
When our websites/apps/applications contain links to other sites and resources provided by third parties, these links are for your information only. They should not be interpreted as our approval of those linked websites or the information you may obtain from them. We have no control over the contents of those external sites or resources shared.
24.3 User-Generated Content on Websites/Apps/Applications or Volunteering Hub
Our websites/apps/applications may include information and materials uploaded by other users. However, we have not verified or approved this content, and we do not accept liability for any errors, omissions, or inaccuracies in submitted material. The views expressed by other users on our site do not necessarily represent our views or values.
24.4 Organisation-Generated Content on Websites/Apps/Applications or Volunteering Hub
Our websites/apps/applications may include information and materials uploaded by organisation representatives or employees. We are committed to checking this information through a manual approval process before making information and materials live on the ‘Volunteering Hub’. We do not accept liability for any errors, omissions, or inaccuracies in submitted materials or information.
24.5 Organisations, Representatives, and Employees Responsibilities When Posting Content to the ‘Volunteering Hub’
Organisations, representatives, or employees can be approved to add opportunities to our ‘Volunteering Hub’ that forms part of our websites/apps/applications. As an organisation, representative, or employee, it is their responsibility to ensure that the content, materials, and information being submitted are accurate and correct. Organisations, representatives, or employees are held responsible for their submissions.
While we do our best to ensure the authenticity of the submitted content, we do not endorse or confirm the authenticity of the content other than the original onboarding verification process and manual approval checks. This does not serve as an endorsement.
24.6 Organisation Registration for Posting Opportunities
Organisations must provide contact details, insurance information, safeguarding and volunteering policies, and confirm DBS checks for Volunteer Coordinators. The registration process includes verification and approval by our team.
24.6.1 Data Collection and Use
We collect contact details, insurance documents, and policy documents to vet organisations and ensure compliance. This data is used for communication and verification purposes as part of our processing to safeguard our application and its users.
24.6.1.2 Insurance and Policies
Organisations must upload their insurance documents and confirm their coverage for volunteers. Organisations are responsible for ensuring their insurance is up-to-date and in place.
24.6.1.3 Data Storage and Security around Organisations
Data provided by your organisation regarding its policies and insurance requested through our vetting process is stored securely and additional data in encrypted spreadsheets. We implement measures such as encryption and access controls to protect your data. We hold this data until it is no longer required or when your account, opportunities and information are no longer available on our websites/apps/application. Your organisation can request that we remove this data we hold at any time by emailing info@innovate-trust.org.uk
24.7 Application Process for Opportunities
Members can apply for volunteer opportunities via the email or phone number provided in the listings. The Volunteer Hub is designed to be accessible and easy to use. We do not accept responsibility for any inaccuracies.
24.8 Approval and Misinformation
All volunteer opportunities are manually approved by our team to ensure accuracy and relevance. However, there is still a risk of misinformation or sharing of incorrect information. We only allow vetted organisations to post opportunities on the volunteering hub opportunities listings. We accept no liability for misrepresentation, errors, inaccuracies, or omissions related to the opportunities posted.
24.9 Content and Resources
The Volunteer Hub includes videos showcasing opportunities, articles, guides for organisations and easy-read guides on volunteering. We have made every effort to ensure that these are factually accurate but accept no responsibility for misinformation, errors, or omissions.
Unless otherwise stated, we are the owner or the licensee of all videos, articles, guides and easy-read guides on the Volunteering Hub. These works are protected by copyright laws and treaties around the world. All such rights are reserved. Our logos, graphics or images may not be copied or retransmitted without our prior written permission; this extends to the design or layout of our websites/apps/applications including the Volunteering Hub which may not be copied in whole or in part.
Subject to the exclusions set out above, you may print in hard copy, download to a local hard disk or otherwise use the guides for organisations and easy-read guides on the Volunteering Hub, provided it is for your personal use or only accessible by others within your organisation. The supply of any copy to a third party is permitted provided it is for their own personal use; it is not supplied as part of another work or publication and is not supplied directly in return for commercial gain. The supply of copy to a third party is conditional upon them being made aware of the fact that these terms apply equally to them.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Translation is permitted on the basis that you take full responsibility for the accuracy of the translation.
Our status (and that of any identified contributors) as the authors of content on our websites/apps/applications must always be acknowledged. All copyright and proprietary notices must be kept intact, and our logos, address and contact details reproduced.
Permission to utilise the resources set out above, does not extend to any material on our websites/app/applications which is identified as being the copyright of a third party. Authorisation to reproduce such material must be obtained directly from the relevant copyright holder.
If you print off, copy or download any part of our websites/apps/applications in breach of these terms of use, your right to use our websites/apps/applications will cease immediately and you must return or destroy any copies of the materials you have made.
If you wish to contact us, please email us at info@innovate-trust.org.uk or call on 02920 382151
Last updated: March 2025